First Aid Requirements by State in Australia: A Guide for Multi-State Businesses

A business with sites in Melbourne, Perth and Sydney answers to three different regulators under two separate legal frameworks. Almost every workplace first aid guide online is written as though you operate in a single state, and that is exactly where multi-site operators come unstuck. First aid requirements by state in Australia are not one national rulebook. The gaps are small enough to miss on a walk-through and large enough to fail an inspection.

If you run first aid compliance across state lines, the job is not to learn nine separate systems. It is to know which parts are shared, which parts are genuinely different, and how to set one internal standard built to meet the toughest of them. This guide maps the legal landscape, then hands you a way to standardise. It sits alongside our wider guide to workplace first aid compliance in Australia.

Are first aid requirements the same in every Australian state?

No. Every state and territory except Victoria works under the harmonised model Work Health and Safety laws, where regulation 42 of the model WHS Regulations sets the binding duty to provide first aid. Victoria runs its own Occupational Health and Safety Act 2004 and Regulations 2017. Western Australia is harmonised but keeps local variations.

That single split, harmonised versus Victoria, with Western Australia as a harmonised-but-local case, is the whole story. Get it right and one national kit specification travels across your sites. Get it wrong and you build to the wrong instrument in at least one state, then find out during an inspection rather than before it.

One country, two legal frameworks

The model work health and safety laws were agreed in 2011 and took effect from 2012, and most of Australia has run on that harmonised system since. Safe Work Australia develops model work health and safety laws, and each state, territory and the Commonwealth enacts its own version of them. The binding obligation to provide first aid sits in the regulations, at regulation 42, the Duty to provide first aid. It requires a business to make sure first aid equipment, facilities and access to trained first aiders are available to workers.

Safe Work Australia's model Code of Practice, First aid in the workplace, is guidance on how to meet that duty. It is not the duty itself. That distinction matters when you are separating what is legally required from what is recommended good practice.

Australian workplace first aid legislation splits along that one fault line, because two jurisdictions sit outside the harmonised regulations. Victoria never adopted the model laws, and Western Australia adopted them late and with local changes. That is why first aid requirements by state matter to anyone running more than one site.

What Victoria requires

Victoria runs its own framework and always has. Employers there work under the Occupational Health and Safety Act 2004 and the Occupational Health and Safety Regulations 2017, regulated by WorkSafe Victoria. The practical guidance is WorkSafe Victoria's Compliance Code: First aid in the workplace, updated in 2021.

A Victorian compliance code carries a specific legal status. Follow it and you are deemed to comply with the matching duty under the Act. Depart from it and you can still comply, but you have to show your alternative meets the same standard.

The first aid compliance code Victoria publishes then gives you two ways to meet that duty, and you choose the one that suits the workplace. Option 1, the prescribed approach, sets the numbers for you: how many first aid officers, kits and first aid rooms to provide, based on the level of risk and the number of employees. Option 2, the risk assessment approach, works from your own hazards, site layout and distance from medical help, and the Code steers large or complex workplaces towards it. If your only compliance knowledge comes from the national Code, you are reading the wrong document for your Melbourne site.

What the harmonised states and territories require

New South Wales, Queensland, South Australia, Tasmania, the Australian Capital Territory, the Northern Territory and the Commonwealth all run the harmonised model. The duty is regulation 42, and the model Code of Practice, First aid in the workplace, is the guidance their regulators point to. In practice, a kit and staffing setup built to the model Code follows the guidance every one of these regulators points to. The Code is guidance, though, so the test in each jurisdiction is still whether your setup meets regulation 42 for your own hazards.

Western Australia is the case to watch. It adopted the model WHS laws through the Work Health and Safety Act 2020 (WA), which commenced on 31 March 2022, so it is now broadly harmonised. But WA made its own regulations with local variations and is administered separately by WorkSafe WA.

Treat WA as harmonised in principle, then confirm the WA-specific detail against WorkSafe WA before assuming a New South Wales setup transfers unchanged. Do not treat it as a third un-harmonised regime, and do not assume it is identical to the eastern states either.

The jurisdiction matrix

The table below sets out the WHS first aid regulations by state and territory, where the binding duty lives, and the regulator that enforces it. Where a jurisdiction has local detail, confirm it against that regulator before you act, because instruments are amended over time.

How to run one compliance standard across every site

The mistake multi-site operators make is managing each state as a separate project. The efficient move is the opposite. Set one internal standard built to the strictest requirement across all your sites, so every site is held to the same bar and the local detail is checked once rather than nine times.

In practice that means three things. Pick one kit specification, matched to your highest-risk site and its hazards, and roll it out everywhere so a Perth kit and a Hobart kit are identical. Set one first aider training and ratio standard to the toughest applicable level, so shift coverage is never short in any state.

Keep one records system for checks, restocks and expiry dates, so you can produce evidence for any regulator on request. National business first aid compliance is far cheaper to run as one standard than as nine.

We assemble and supply workplace kits to a single specification, so a national rollout is one order rather than nine separate ones. For the numbers behind how many kits each site needs and where they sit, work through how many first aid kits your workplace needs and, for your higher-hazard locations, remote and high-risk workplace kit requirements. The records side is covered in first aid compliance records.

One records system for every site

One standard still needs one place to prove it. For a national operator, that means a single audit trail across state lines: which kit was checked, when, what was restocked, and what is due. When an inspector in any state asks for evidence, you want one export rather than a scramble through nine spreadsheets. If you'd rather keep that trail in software than in a spreadsheet, KitCheck is a subscription to our proprietary kit management software, which your own staff log in to and run across every site.

For businesses in and around Bendigo, we can do the physical check for you onsite: ask about onsite audits and restocks when you call or email using the details below. Sites anywhere else in Australia stay on the same specification with first aid kit refills and a trade account, so every location restocks from the same list.

Operate across state lines? Set one national standard and stock every site from our workplace first aid kits range. To set up a trade account, call 03 5443 2239 or email info@firstaiddistributions.com.au.

Related articles

• How Many First Aid Kits Are Required in the Workplace in Australia?
• Remote and High-Risk Workplace First Aid Kit Requirements
• First Aid Compliance Documentation: What Records Your Workplace Should Keep